ML20138G226
| ML20138G226 | |
| Person / Time | |
|---|---|
| Issue date: | 10/15/1996 |
| From: | Travers W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9610210001 | |
| Download: ML20138G226 (15) | |
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UNITED STATES s
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001
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October 15, 1996 MEMORANDUM T0:
Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards FROM:
William D. Travers, Director Spent Fuel Program Office Office of Nuclear Material Safety and Safeguards
SUBJECT:
PERFORMANCE ASSESSMENT PROGRAM PLAN FOR VENDORS AND FABRICATORS OF INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS The Spent Fuel Project Office (SFP0), has developed a program plan for assessing performance of vendors and fabricators of Independent Spent Fuel Storage Installations (ISFSIs). We will prepare brief, qualitative, periodic assessment of licensee performance to be expressed in a number of functional areas. The assessment will be used by NRC to focus on the strengths and weaknesses of licensee activities.
This assessment will facilitate our license review and focus our inspection efforts, as well as to facilitate the licensees' self-improvement programs.
There is a need for a comprehensive overview of licensee performance regarding spent fuel activities for a number of reasons.
NRC has already developed and implemented performance assessment programs for nuclear power plant operations (SALP) and for fuel cycle facilities (MC'2604).
The quality of the license applications that we have received so far has shown a wide variation in depth of technical analysis and responsiveness to licensing reviews; and, conse-quently, we have not been able to plan the resource requirements adequately.
We also want to allocate our inspections resources based on licensee performance. An increased level of public attention has also been directed lately to the design, licensing, installation and operation of ISFSIs necessitating a more systematic assessment of all aspects of licensee activities.
The goals, tasks and schedule of the planned effort are delineated in the enchsed Program Plan.
The initial phase of this program, planned in a total of three phases, includes development of a draft Manual Chapter procedure for the conduct of the assessments, and completing three pilot assessments.
Based on the lessons learned from the pilots, we will refine the draft procedure, validate it with additional assessments, and initiate a periodic performance assessment process.
The assessment will be performed on a routine basis to include all entities active in the design and fabrication of ISFSIs.
Periodicity of assessments will depend on the level, timing and intensity of licensee activities, and will be adjusted in accordance wi'.h performance. We estimate that approximately 0.78 FTE will be needed to support the program for Phases 1 and 2; and that 0.35-0.45 FTE will be needed yearly for its routine implementation.
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9610210001 961015 PDR ORG NOMA PDR
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C. J. Paperiello We expect that with the successful implementation of this program, we will facilitate our licensing process and reduce the number of nonconformances in future inspections.
Unless otherwise advised, we will initiate Phase 1 (develop draft procedure) and continue with Phase 2 (conduct pilot assessments).
Enclosures:
- 1. Program Plan for ISFSI j
Performance Assessment
- 2. Outline of Draft Assessment Procedure
- 3. Flowchart of the Assessment Process
- 4. Generic Schedule for Conduct of Assessments i
Distribution:
NRC F/C PUBLIC SFP0 r/f SCDB r/f JJankovich JSpets FSturz Eleeds OFC sfMFP0 6
SFP0 u
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fP0 jf SF W NAME hankovich/1g S M an NHaughney Ners DATE l07(/96 (D/l/96
[O/(f/96 ID/If/96 C = COVER ** E = COVER & ENCLOSURE ** N = NO COPY PAPP.MEM 0FFICIAL RECORD COPY
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i Program Plan For ISFSI Performance Assessment Objective:
SFP0 will develop a process for conducting performance assessments of vendors and fabricators of independent spent fuel storage installations (ISFSIs).
The performance assessment will include all aspects of activities, e.g.,
application for Certificate of Compliance (C0C), system design, and fabrication.
SFP0 will develop a method to prepare brief periodic assessments regarding specified functional areas based upon existing data and staff interaction with i
licensees. The method will provide a standardized, simple process for periodic performance assessment of ISFSI licensees.
In cases where the significance of the assessment warrants, the assessment results may also be presented by NRC management to the licensee at a meeting open for public observation.
The proposed approach is similar to the one that was developed in 1995-96 for fuel cycle facilities.
The fuel cycle licensee assessment process was formalized by the issuance of Manual Chapter 2604.
Approach and Milestones:
SFP0 will develop the assessment method to present a qualitative overview to NRC management of the licensee's overall performance including strengths and weakne~sses; but the licensees will not'be quantitatively rated or ranked collectively as a result of the performance assessment The performance review program will also provide feedback to licensees regarding how NRC i
perceives their performance in protecting public health and safety.
Such feedback is expected to heighten the licensees' awareness of areas where improvements are most needed and, consequently, should enhance their overall future performance.
With regard to NRC-licensee management meetings, we will develop guidelines to determine whether such meetings are warranted. The guidelines will provide means to determine the significance of the assessment results and basis for a management meeting.
We intend to conduct this program in three phases.
SFP0 will develop a draft procedure in the format of a manual chapter document, validite the draft through a set a pilot assessments, finalize the c' raft, and initiate implementation of an assessment program.
Specifically, we anticipate the following major milestones in the program:
ENCLOSURE 1
o Phase I Development of Assessment System develop draft manual chapter 12/96 define " licensees" select functional areas and rating criteria identify input sources conduct pilot assessments 06/97 select candidate licensees perform three pilot assessments (e.g., Sierra, Vectra, Transnuclear)
Phase 11 Refinement of Assessment Method develop final manual chapter summarize pilot results 08/97 conduct addition assessment 09-11/97 i
issue final manual chapter 12/97 Phase III Implementation start 01/98 1
conduct assessments Assessment Target Group (" licensees"):
We propose to include two categories of entities in the assessment program. A third category is listed as an " option."
(1)
Part 72 licensees not holding Part 50 licenses, as well as applicants for Part 72 licenses, e.g. GE Horris, Ft. St. Vrian (after transfer to DOE), Rancho Seco (after termination of Part 50 license), Trojan (after termination of Part 50 license), DOE (for THI-2 fuel), DOE (Central Interim Fuel Storage Facility),
(2)
C0C holders, applicants, and fabricators.
Includes submitters of topical reports such as Transnuclear, Foster / Wheeler.
(3)
(0ption) Part 50 Licensees with ISFSIs. We do not plan to include these licensees at this time because their ISFSI activities could be addressed in the SALP process.
Functional Areas:
The licensees' performance will be assessed for each of a number of functional areas. A functional area is defined as a distinct activity that the licensee accomplishes regarding the design, development, licensing and acquisition of the ISFSI.
Identification of the functional areas will require detailed analysis. We have developed an initial list of functional areas listed below.
We recommend the use of these for the pilot assessments.
Based on the results of Phase I, we 2
use of these for the pilot assessments.
Based on the results of Phase I, we
-will refine these functional areas, delete those that are not relevant, and add new ones if needed.
The functional areas have been selected to encompass design and fabrication processes.
1.
Design Process:
Design activities - assessment based on the results of design review a.
inspections b.
Quality of application - assessment based on the completeness of SAR, scope and significance of request for additional information (RAIs) necessitated by NRC's review of the application, and tise applicants response to RAIs Design changes - assessment based on the licensee's handling and c.
resolution of Part 72.48 issues d.
Mechanical, materials, functional problems in the system - based on generic issues (e.g., Pt. Beach hydrogen generation) 2.
Fabrication Process:
a.
Fabricator selection - assessment based on vendor selection and oversight b.
Fabricator performance - based on vendor inspections c.
Interface with Part 50 licensees d.
Interaction with the public - based on responte to citizens, participation in public meetings Periodicity of Astessments:
A fixed assessment period, such as 12 months or 18 months, cannot be assigned to the performance of assessments because the application for C0C and fabrication are not performed on a continual baris (as the continual operation of a nuclear power plant where the SALP ratings could be performed routinely).
For ISFSI activities the assessments must be tied to the activities being performed and adjusted for performance. Therefore, we intend to perform an assessment of those licensees who are active, e.g., have applied for a C00, are in the process of designing new systems, or have developed and fabricated dry storage units.
SFP0's master inspection plan will be used to select candidate licensees and the timing for the assessments.
SFP0 will enter the assessment schedule into the SFP0 Operating Plan for the Director /NMSS to be informed about the status of the assessments.
3
Those licensees who are active on a continual basis (e.g., as Vectra and Sierra, have been in.the 1995-96 period) would be assessed early within this program and then on a periodic basis of 24 months.
Responsibilities and Information Sources:
SFP0 will be responsible for the development of the manual chapter specifying the conduct of the performance assessments.
SFP0 will perform the pilot assessments scheduled for Phase I and prepare and finalize the procedure in the Manual Chapter in Phase II.
SFP0 will be the lead organization for the routine assessments scheduled for Phase III.
It must be noted that the role of the regional offices will be smaller in the ISFSI assessment program than in other assessment activities, (SALP, Fuel Cycle Licensee Performance Assessments), since most of the certificat.on activities are accomplished at headquarters and design and vendor inspections are conducted by headquarters.
Presently we anticipate that most of the information for the assessment process will originate from sources within SFP0.
Specifically, the information will be gathered from the following sources: (1) Spent Fuel Licensing Section, (2) Spent Fuel Technical Review Section, (3) Transportation and Storage Inspection Section. Additional information will be collected from NRR, RES, and the Regional Offices as applicable.
The specific roles of the other offices such as NRR, RES, and the Regions will be determined during Phases I and II.
The proposed manual chapter will delineate the nature and the extent of th.e functions of the various offices in the assessment process.
Resource Rcquirements:
We anticipate that, within SFP0, the Transportation and Storage Inspection Section will develop and implement the assessment program.
Specifically, we project the following resource requirements as shown on Table 1.
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- Resource Estimates;;
iPeriod2
- (staff weeks)!
Phase I -
Develop Draft MC 4
10-12/96 Phase II - Conduct 3 pilot assessments 18 1-6/97 (collect inputs, write report, prepare and administer management meetings): 6 staff weeks each Phase II - Develop final MC 4
6-9/97 Conduct 1 additional 6
8-10/97 assessment to validate MC Issue final MC 3
11-12/97 TOTAL STAFF WEEKS 35 (i.e. 1400 hrs or 0.78 FTE)
Phase III - routine assessments 15-20 or, going (collect inputs, write reports, prepare (I.e. 600-800 hrs yarly and administer management meetings): 5 or 0.35-0.45 FTE) staff weeks each, 3-4 assessments / year Revise MC - once/3 years 4
once every 3 years 5
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, Outline of Draft Assessment Procedure NRC INSPECTION MANUAL NMSS MANUAL CHAPTER XXXX INDEPENDENT SPENT FUEL STORAGE INSTALLATION PERFORMANCE ASSESSMENT XXXX-01 PURPOSE The purpose of this chapter is to provide a process for conducting Performance Assessments (PA) of key functional areas covered by licensing and inspection programs for Independent Spent Fuel Storage Facilities (ISFSI).
This process will provide senior management with an overview of licensee performance.
PA results will be used by NRC management for licensing and inspection planning and resource allocation to ensure the continued protection of the worker, public, and environment.
Assessment results will also be provided to the licensee, as information, to assist them in improving their overall performance and for focussing resources and attention on specific weaknesses.
The scope of this procedure includes ISFSI design, fabrication, licensing, and Certificate of Compliance a the scope. pplication. Operations and on-site construction are not included in XXXX-02 OBJECTIVES 02.01 To describe the process for conducting ISFSI pas 02.02 To provide PA results in a format that is usable to senior management for decision making purposes 02.03 To ensure pas are performed consistently 02.04 To minimize subjectivity by ensuring, to the maximum extent possible, objective evidence is used in the assessment process XXXX-03 DEFINITIONS 03.01 Assessment Taraet Grouo (" licensee").
Part 72 licensee not holding Part 50 licenses, applicants for Part 72 licenses. DOE (for TMI fuel). DOE (Central Interim Fuel Storage Facility). C0C holders, applicants. ISFSI fabricators, and vendors. Part 50 licensees with ISFSIs are currently not include because their ISFSI activities could be addressed in the SALP process.
03.02 Assessment Format. For purposes of this program, this indicates an outline type of format where licensee performance information is presented in concise terms for functional areas, in terms of overall rating, program strengths.
program elements needing improvement, and program elements for which challenges to performance are expected during the next review period.
Under each of these categories, items of information may be indicated with " bullets" (e.g.. "*").
Issue Date: XXXX 1-XXXX ENCLOSURE 2
Where further details are to be specified, items of information are indicated by hyphens (e.g.. "- ).
03.03 Indeoendent Soent Fuel Storaae Installation (ISFSI).
A complex designed i
and constructed for the interim storage of spent nuclear fuel and other radioactive material associated with spent fuel storage.
03.04 The following describes the two main functional areas that form the basis of an assessment.
1.
Design Process:
a.
Design activities - assessment based on the results of design review j
inspections b.
Quality of application - assessment based on the completeness of SAR.
scope and significance of request for additional information (RAIs) necessitated by NRC's review of the application, and the applicants response to RAls c.
Design changes - assessment based on the licensee's handling and resolution of Part 72.48 issues i
d.
Mechanical, materials, functional problems in the system - based on j
generic issues (e.g., Pt. Beach hydrogen generation) 2.
Fabrication Process:
a.
Fabricator selection - assessment based on vendor selection and oversight b.
Fabricator performance - based on vendor inspections c.
Interface with Part 50 licensees d.
Interaction with the public based on response to citizens, participation in public meetings XXXX-04 RESPONSIBILITIES AND AUTHORITIES 04.01 Director. Office of Nuclear Material Safety and Safeauards (NMSS) a.
Receive briefing from staff on PA results.
b.
Optionally, meet with " licensee" senior management after being briefed by staff, to discuss the performance assessment.
j 04.02 Director. Soent Fuel Pro.iect Office (SFP0) a.
Determine / concur to which " licensee" will be subject to this program.
b.
Provide appropriate personnel to participate in assessments.
c.
Optionally, participate in assessments, d.
Review and issue Performance Assessment Reports (PAR).
before presentation to NRC senior management (Directcr. NMSS).
4 e.
Brief NRC senior management on assessment results and present report.
XXXX 2-Issue Date: XXXX
f.
Issue Performance Assessment Letter and Report to " licensee".
9 Arranges for open meeting with " licensee" senior management, after briefing of NRC senior management (if warranted).
h.
Determine / concur to approximate interval between " licensee" assessments.
Interval will vary, based on previous performance and the safety risk of ISFSI.
I.
Determine and implement modifications to program, as necessary.
J.
Review " licensee" response if required.
04.03 ReQional Director. DNMS.
_')ivision aDDroDriate (for resDonsible reQion) a.
Provide appropriate personnel to participate in or provide information for the assessments (as applicable).
B.
Make available, to the Public Document Room, copies of Performance Assessment Letter and Report, and appropriate information presented by
" licensee", relevant to " licensee" performance, after meetings with
" licensee" senior management.
04.04 Performance Assessment Coordinator (PAC) a.
Develop and maintain schedule of assessments b.
Coordinate all assessment activities including correspondences, meetings, information gathering, agendas, etc.
c.
Interface with management and act as the program focal point.
d.
Write the PAR after obtaining input from PAT.
e.
Respond to Director SFP0 questions and concerns regarding assessments.
f.
Develop presentation material including overheads, handouts, reports, etc.
g.
Participate in briefing and report presentation to NRC senior management.
h.
Review " licensee" response if required.
04.05 Performance Assessment Team (PAT) a.
Perform assessments in areas of expertise, b.
Provide input to the ISFSI PAR.
c.
Participate in briefing and report presentation to senior management.
d.
Provide backup documentation to assessment results.
e.
Assist PAC as required.
f.
Attend all required assessment meetings.
g.
Review licensee response if required.
Issue Date: XXXX 3-XXXX
XXXX-05 PROGRAM OVERVIEW
^
The assessment 3rogram takes " licensee" ISFSI activities and categorizes them into individual functional areas.
The assessment is performed by a PAT consisting of individuals involved in licensing and inspection programs of the ISFSI.
Team members are considered experts in the area assigned.
The team is lead and the assessment coordinated by the PAC. The PAC is assigned by Director SFPO.
Functional areas are assessed to a common set of criteria based on past inspections, correspondence, reviewed documentation, etc..
When the assessments of the individual functional areas are completed the main functional area is assessed.
The assessment report is written by the PAC with input by the PAT.
The report is presented to management by the PAC and select PAT members.
Management has the option of meeting with the licensee.
XXXX-06 BASIC REQUIREMENTS (outline not yet expanded) 06-01 Director SFP0 assigns PAC.
06-02 PAC determines proposed assessment schedule for current year and provides a best estimate to schedule for out years.
PAC required to review and revise schedules yearly.
06-03 DSFP0 reviews and concurs to proposed schedules.
06-04 PAC distributes proposed schedules to potential PAT members (e.g., SAR reviewers, inspectores, etc.) as information (heads-up).
Schedules are subject to change and are not binding.
06-05 Upon initiation of actual assessment. PAC determines PAT members.
06-06 DSFP0 concurs to PAT members or modifies as appropriate.
06-07 PAC notifies personnel that they have been choosen to be part of the PAT.
describes assessment scope, PAT responsibilities, and PA time frames / schedule (see Enclosure XX).
06-08 Assessment of functional areas can be pe-med by use of any available information. Following are a few examples of iniut mation which can be utilized in the assessmnet process.
Review of Quality Assurance Inspection Reports for Shipping and Storage Containers.
Review of correspondences (e.g., request for more information.
number and type of cornents to documentation submitted for approval, etc.)
Review of enforcement actions.
Review of time frames (e.g.,
document
- review, turnaround, fabrication and construction,
- startup, corrective action implemetation, responce to request, etc.)
Review of Nort-Conformances.
Review of requested changes.
Review of site ins)ection.
Review of basic cocumentation (e.g., Certificate of Compliance.
Previous inspection reports, previous evaluations, Safety Evaluation Reports, Quality Assurance Program Applications Safety Analysis Reports, Organizational Charts.
Procedures. Quality Assurance Plans / Records. Test Reports. Audit Reports, etc.)
XXXX 4-Issue Date: XXXX
06-09 The Functional Area Asc,essment Criteria consist of the following.
Excellent - Overall performance surpasses regulatory requirements and applicable commitments. Guidelines are fully documented and implemented.
Satisfactory - Applicable elements of this program have been developed.
documented, and implemented so that the regulatory requirements or applicable commitments are met.
Some areas may require improvement.
Unsatisfactory - Inadequate or no effort has been made in this specific area. and does not meet regulatory requirements or applicable commitments.
Documentation or implementation is missing or inadequate.
06-10 PA meeting is scheduled and chaired by the PAC and is atteneded by the PA1 members and any interested management.
06-11 PAT members are required to bring to the meeting their individual functional area assessment results (e.g., EXCELLENT. SAT UNSAT.), supporting documentation, strengths, weaknessses, and recomendations.
06-12 Each PAT member will present their results at the meeting.
Results will be discussed and cocurred to.
Each main functional area will be assessd by the PAT based on the individual functional area results.
Main functional area Strengths. Weeknesses, and recomendations will also be determined.
06-13 The PAC will write the PA report based on the meeting results. PAT members will assist the PAC in repport preparation as required.
06-14 DSFP0 will concur to the report.
06-15 The PAC will prepare the presentation, with PAT assissstance if required, for senior management.. Presentation will' be approved by DSFPO.
06-16 PA report will be presented to senior management. Any requested changes to the report will be made.
06-17 Letter with PA report will be sent to " licensee" 06-18 NRC meet with " licensee" senior management if warranted.
06-19 Action will be taken based on management direction (e.g., increase inspections decrease inspections refuse initial applications)
Issue Date: XXXX 5-XXXX
Enclosurs 3 Page i of 2 l
FLOWCHART OF ASSESSMENT PROCESS i
PAC DETERMINE AND l MAINTA3N PERFORMANCE 1
[ ASSESSMENT SCHEDULE PAC PERFORMANCE ASSESSMENT l l
COORDINATOR y
PAT PERFORMANCE ASSESSMENT O! RECTOR SFPC REVIEW TEAM AND CCNCUR TO g -PROPOSED SCHEDULE SFPO. SPENT FUEL PROJECT OFFICE l
Y PAC S ELECT PAT MEMB ERS FOR ACTUAL PERFORMANCE ASSESSMENT Y
DIRECTOR SFPO CONCUR TO PAT MEMBERS l
Y l PAC NCTJ.*V PAT M EMBERS OF
{
SIGN E NS B L
$E I
Y PAT COMPILE SOUROE UNFORMAT0CN AND ASSESS Y
PAT AND PAC ATTEND INTER:M WORK 3NG MEETING l
t PAT AND PAC DISCUSS AND CONCUR TO ASSESSMENTS Y
PAC WRITE PERFORMANCE ASSESSMNET REPORT r
OlRECTOR SFPC SIGN CUT ASSESSMENT REPORT Y
PAC PREPARE BRIEFING MATERIAL Y
(CONTINUED ON PAGE 2)
ENCLOSURE 3
s Endoeure 3 Page 2 of 2 FLOWCHART OF ASSESSMENT PROCESS (CONTINUED FROM PAGE 1) l Y
SR3EF SENIOR MANAGEMENT ON ASSESSMENT AND
?*RES ENT REPORT
/
MEETING ygg l
- l ENR o LS$ kd_E LIC N EE l
'WARRANTEQ y
NO l NRC MEET W3TH UCENSEE y
SENICR MANAGEMENT LEWER W3TH ASSOCIATED l
REPORT TO LICENSEE y
l REVIEW LICENSEE RESPONSE V
NO LICEN'SEE YES
/
RESPONSE
NEEDED i
i y
v NO ACTION REQUIRED LICENSEE RESPOND TO DY LICENSEE WEAXNESSES l
1 V
REVIEW LICENSEE RESPONSc i
J i
}
Y PAC CEFINES NEXT ASSESSMENT OYCLE l
V (CONTINUE PROCESS) s
o r
\\
Generic Schedule for Conduct of Assessments TIME SINCE REVIEW ACTION' WAS INITIATED Start Assessment coordinator informs team of assessment scope and time frame. The coordinator requests team members to compile source information and assessment results to be used at interim working meeting.
3 weeks Interim working meeting is held to allow the assessment team the opportunity to discuss and concur to assessment results.
8 weeks The assessment coordinator writes the assessment report with input from team members. Director, SFPO signs-out completed report.
10 weeks Director, SFPO, with assessment coordinator and select team members, brief Director, NMSS on assessment results and present report.
12 weeks Director, SFPO issue letter and report to licensee.
14 weeks Director, SFPO arrange for meeting of NRC senior management and licensee senior management if warranted.
15 weeks NRC meet with licensee senior management.
l ENCLOSURE 4
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